Executive Rights: Duty Owed by Executive Rights Owners to Non-Participating Royalty Owners

摘要

Steadfast Financial, L.L.C. (Steadfast) owned all the surface and mineral rights to 1,800 acres in Hood County, Texas. In 2006, Steadfast sold the surface to Range Resources (Range) and then granted an oil and gas lease to Range that provided for a l/8th royalty. Betty Lou Bradshaw (Bradshaw) owned a non-participating royalty interest (NPRI) in the 1,800 acres. The NPRI entitled Bradshaw to 1/2 of any lessor's royalty reserved by the mineral owner in any oil and gas lease over the captioned land Steadfast then assigned portions of its lessor's royalty interest to various parties. Bradshaw sued, claiming mat royalty rates in the region in 2006 for oil and gas leases were l/4th, and that Steadfast had a duty as the executive rights owner to get the highest royalty possible.